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Review of the Australian Code for the Responsible Conduct of Research Submission

Personal Details
This submission reflects the views of
Organisation Name: 
Griffith University
Specific comments
Specific comments: 
Specific consultation questions
Question 1: Do you like the new approach to the Code, namely the principles-based document being supported by several guides that provide advice on implementation?: 
A short principles-based Code supported by ‘best practice’ guides better enables an institution to formulate arrangements that are tailored for its research community and discipline mix. Such an approach encourages institutions to focus upon research integrity as a research culture and research practice concern, not ‘just’ a compliance matter. Griffith University also recommends that research institutions be afforded the opportunity to share ideas on the implementation of new Code. To this end it would be worthwhile for a short practitioner conference to be held (including a strong digital participation option), with a blending of keynote, plenary session and professional development workshops. Such an event could be sponsored jointly by the NHMRC, ARC and UA. Griffith notes that attention will be given in the near future to producing a guide on Authorship which in our experience is probably the most common area of dispute between researchers that can result in breaches of the Australian Code. We recommend that emphasis be given to producing an unambiguous single national authorship standard for Australia that aligns with international standards. This will reduce the incidence of disputes between Australian researchers and international colleagues and between Australian researchers based at different institutions. #1 Ideally the guidance material should align with that produced by the Committee on Publication Ethics (COPE), the US Office of Research Integrity, and the International Committee of Medical Journal Editors.
Question 2:The draft Code is intended to be used by all research disciplines. Do the principles adequately capture the expectations for responsible research across all research disciplines?: 
One strength of the new approach (short principle based Code and supporting guides) is that it can be readily applied across research disciplines. Having achieved this standard it is probable that the Australian research community will have similar expectations for future guides. Given the appreciable differences in practice between disciplines (e.g. comparing the publication ethics realities in engineering, humanities and medicine) it is essential that reference groups have the membership needed to represent a wide range of disciplinary expertise. It is worth investing time in the development of these guidelines with broad consultation to assure that they can be operationalised fairly and effectively across all discipline contexts.
Question 3: The draft Guide refers to breaches of the Code rather than providing a definition of research misconduct, and states that institutions can decide whether or not to use the term research misconduct in their own processes.: 
The reference to breaches of the Code, rather than defining research misconduct, will avoid conflict and confusion between enterprise agreements and research processes. This is a major step forward. There are several likely issues arising: 1. Aligning the arrangements with enterprise agreements to achieve a level of consistency across the sector. 2. The NHMRC and ARC will need to maintain a high level of consistency in policies regarding the thresholds for notification of major departures from the Code. 3. Institutional resource material and processes will need to interpret how Guides have been implemented locally to ensure transparency, consistency and procedural fairness. Ideally institutional approaches need to be well aligned across the sector, hence the earlier recommendation for a short practitioner conference to discuss implementation. The achievement of consistency in the implementation of the Code across the sector is therefore a key concern.
Question 4: Do you think the process described for investigating and managing potential breaches of the Code is clearly described and practical?: 
The process discussed in the draft is vastly superior to the existing Australian Code. Some minor comments are that: 1. Griffith accepts that institutions are best served by ensuring a coordinated approach to complaint management however will reserve the right to determine the most suitable approach on a case-by-case basis and continue to use departmental level processes (where appropriate) to reach a mutually acceptable agreement or to mediate a resolution. 2. The acceptance and consideration of confidential and anonymous allegations will require careful consideration (e.g. from a natural justice perspective). The Code Review Committee might wish to consider the implications of two institutions being a party to an investigation if they have varying stances on confidential and anonymous allegations. Griffith supports several points made in the Australian Higher Education Industrial Association submission relating to section 7 (Investigation Stage). Key concerns are: Section 7.4 – the suggestion that the written report from a Panel should be prepared as a draft for comment by all parties will if implemented lead to further complexities, argument and time delay. Section 7.4.2 – The option in the draft Code to allow for a substitute panel should the original one be unable to make a finding open the door for potential legal complications and suggestions that universities could engineer the process to arrive at a desired outcome.
Question 5: The Code Review Committee and working group are considering what additional resources should be developed to support implementation of the Code and Guide.: 
Case studies would be a welcome resource both for the practical application of the Code and for researcher training and development. One case study to consider is where two institutions are stakeholders on a matter and what would be good practice, especially if the institutions have adopted differing policy settings.
Question 6: Are the mechanisms for review of an investigation clearly and correctly described in Section 7.6 of the Guide? If not, where are the inaccuracies?: 
Griffith University is satisfied with the described mechanism.
Question 7: Please comment on which three topics you would nominate as being the highest priority and why.: 
Griffith University agrees that authorship and the responsible management of data should be the next guides produced. Both areas will be valuable and are of pressing interest to research institutions, researchers, research office staff and representative bodies. We recommend that the next guidance material produced after that should be publication ethics, due to the incidence of such disputes between collaborators at all career stages. All three guides should address issues surrounding HDR supervision and the mentoring of early career researchers because of their importance to the future of responsible research in Australia.
General comments

Griffith University welcomes the revised approach to the Australian Code for the Responsible Conduct of Research and congratulates the Code Review Committee and the Better Practice Guide Working Group on developing two excellent consultation drafts.

Page reviewed: 17 September, 2018